KPMG Taseer Hadi & Co. Chartered Accountants A … brief...5. Multilateral routing, switching and/or processing of payment transactions Any other activity permitted by SBP. 6. Any

© 2018 KPMG Taseer Hadi & Co., a Partnership firm registered in Pakistan and a member firm of the KPMG network of

independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.

A brief on Regulations for Electronic Money Institutions (EMIs)

KPMG Taseer Hadi & Co. Chartered Accountants

© 2019 KPMG Taseer Hadi & Co., a Partnership firm registered in Pakistan and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.

A brief on Regulations for EMIs 2

A brief on Regulations for Electronic Money Institutions

State Bank of Pakistan [“SBP”] vide its circular letter ERD/M&PRD/PR/01/2019-34 dated 1 April 2019 launched Electronic Money Institutions [“EMIs”] Regulations [“Regulations”] that will be licensed by SBP to issue e-money for the digital payment.

Objective

The purpose of these Regulations is to provide regulatory framework for EMIs desirous of offering innovative payment services to the general public; to prescribe minimum service standards and requirements for EMIs to ensure delivery of payment services in a safe, sound and cost effective manner; to outline the permissible activities that can be carried out by an EMI and its agents' network; to provide a baseline for protection of EMI’s customers; and to achieve the SBP’s objective of digital payments and financial inclusion.

Applicability

These Regulations shall come into force with immediate effect.

This publication contains a synopsis of these Regulations. KPMG Taseer Hadi & Co. Chartered Accountants 18 April 2019



Executive Summary

The State Bank of Pakistan [“SBP”] notified Electronic Money Institutions [“EMIs”] Regulations [“Regulations”] which provides a regulatory framework for the institutions desirous of offering innovative, user-friendly and cost-effective low-value payment services to the public.

EMIs may issue e-money payment instrument, distribute e-money payment instruments, redeem e-money payment instruments and any other activity permitted by SBP. e-Money will be used to make payments for goods and services, bill payments, fund transfers and cash deposits and withdrawals from e-money accounts. However, EMI will not conduct the business of banking including the acceptance of funds from public for the purpose of lending, investments or any speculative activity. EMI will take approval from SBP before offering any e-money products/services to customers including cross-border payments. EMI will neither pay interest/returns to customers in connection with the length of time e-money is held by consumers nor shall offer anything that adds to the monetary value of e-money. EMI will not issue e-money payment instruments at a discount i.e. issue e-money payment instruments that has a monetary value greater than the funds received from customers and e-money platforms shall only be used for permissible activities. SBP will require the applicant company to establish a separate business entity for e-money business if it may deem fit. SBP reserves the right to reject an application at its discretion. EMIs may be allowed to commence pilot operations (limited-scale real transactions) once they attain operational readiness, fulfill minimum capital and security deposit requirements and any other requirements as mentioned in In-Principle approval.

The main emphasis of these Regulations is on the following areas:

• Scope of activities of EMIs: This include issuance, distribution and redemption of e-money payment instruments along with multilateral routing or any other activity permitted by SBP;

• Licensing of EMIs: This require the registration of the company with SECP along with other requirements under which SBP may grant licensing such as the availability of financial resources and the fulfilment of all requirements as directed after which SBP grants the EMI license in three stages;

• Suspension and revocation of license: SBP reserves the right to revoke or suspend the license of an existing EMI if it’s not in the public interest, illegal, fails to comply with the license conditions or not able to safeguard the funds provided by customers along with



other circumstances. However, SBP shall give notice with grounds to revoke license;

• Governance requirements for EMI: Fit and Proper Test is applicable to key employees of the prospective EMI which proposes that all the Directors and CEO would require proper clearance from SBP before they take on any position in the EMI.

The responsibilities of the Board of Directors include defining the roles and responsibilities of key individuals, ensuring all internal controls such as risk management, IT, audit, security and human resource. The BOD can remove CEO by properly following guidelines;

• Capital Requirement for becoming an EMI: Startup capital requirement for an EMI is PKR 200million and the minimum ongoing capital to be maintained at all times is divided into 4 slabs and the EMI should inform to SBP when the outstanding e-money balance exceeds PKR 20 million; and

• Customer Due Diligence; requirements for EMIs: Customer due diligence is crucial to be fulfilled by the EMI in which the EMI should go about with the customer’s proper details and use two factor authentication for customer verification, along with this the EMI should perform proper due diligence for high risk clients as per SBP guidelines.

The Regulations also encompass other regulatory requirements including outsourcing activities, Anti-Money Laundering and countering of financing terrorism, Consumer Protection, Complaint Handling Mechanism, Oversight, and Regulatory Reporting etc.



A brief on Regulations for Electronic Money Institutions Authority

These Regulations are being issued in exercise of

powers conferred upon State Bank of Pakistan

under provisions of Payment Systems and

Electronic Fund Transfers Act, 2007 [“ PS&EFT

Act”]

Scope of activities of EMIs

Regulation 6

EMIs may engage in the following activities:

1. Issue e-money payment instruments

2. Distribute e-money payment instruments.

3. Redeem e-money payment instruments

4. Acquire payment instruments of other EMIs and

banks/MFBs.

5. Multilateral routing, switching and/or processing

of payment transactions Any other activity

permitted by SBP.

6. Any other activity permitted by SBP.

e-Money platforms shall only be used for

permissible activities.

e-Money shall be used for making payments for

goods and services, bill payments, fund transfers

and cash deposits and withdrawals from e-money

accounts.

EMI:

not to conduct any banking activity (other than

that required under Para 14 of these

regulations) or any speculative activity.

to take approval from SBP before offering

cross-border e-money products/services.

Anything which adds to the monetary value of e-

money shall not be paid to customer and

offered by EMI, however, EMI may offer

discounts on goods and services provided such

discounts which doesn’t affect the amount or

length of time e-money is held by the customer.

not to issue e-money payment instruments at a

discount i.e. issue e-money payment

instruments that has a monetary value greater

than the funds received from customers.

may upgrade their PSO/PSP authorizations to

EMI license after fulfilling necessary conditions

laid down in these Regulations.

to be carried out by establishing separate

subsidiary / entity as may be required by SBP.

Licensing procedure

Regulation 7

The application for EMI license shall be

addressed to “The Director, Payment Systems

Department, State Bank of Pakistan, 4th Floor,

Main Building, I. I. Chundrigar Road, Karachi-

74000” as per Annexure “C”.

The applicant company shall fulfill the following

licensing requirements:

1. The applicant company (public/private) shall

be registered with SECP having its head

office/registered office in Pakistan.

2. The applicant entity shall fulfil all the

application requirements mentioned in

Annexure “C”.

3. The applicant shall have the capability to

efficiently handle all the transactions as an

EMI and fulfil its obligations under PS&EFT

Act and these regulations prior to launching

any product or service under its EMI

license.

4. The applicant shall have necessary financial

resources, policies, procedures, system &

controls, IT systems etc. to efficiently

discharge its responsibilities as an EMI.

5. SBP reserves the right to reject any

application without giving any reason.



SBP may grant EMI license in the following

three stages:

1. “In-Principle” approval to be granted to fulfil

preconditions prior to commencement of

pilot operations of operating as EMI.

2. EMI to commence pilot operations upon

attaining operational readiness, fulfil

requirements mentioned in In-Principle

approval. SBP may also conduct off-site

evaluations/onsite inspections of the EMI at

any stage of the licensing procedure.

3. License to commence commercial

operations shall be granted subject to

satisfactory completion of pilot operations

and fulfilment of all SBP’s requirements.

SBP may suspend/revoke the Approval at any

stage, if EMI fails to comply with the conditions

of SBP Approval in a timely manner. SBP may

give notice of its intention to do so, specifying

the ground(s) upon which it proposes to

suspend/revoke the approval and shall require

the EMI to submit within 30 days, a written

statement of objections to the suspension

/revocation of the approvals.

Suspension/Revocation of License

Regulation 8

SBP may revoke/suspend the license of an EMI if:

revocation/suspension is in public interest;

it is found to be involved in illegal or prohibited

activities;

it fails to comply with conditions of the License;

regulations, rules, guidelines, instructions,

directions and circulars issued by SBP or any

other applicable laws

any information provided by EMI is found to be

misreported to SBP.

it is not able to safeguard the customers’ funds.

it is not able to carry out its operations safely

and efficiently.

provision of e-money issuance by the EMI

endangers the stability of the payment systems

of Pakistan.

it enters into insolvency proceedings.

any other reason substantiating the need for

suspension or revocation of license granted to

EMI.

Before suspending/revoking the license,

SBP shall give notice specifying the ground(s)

upon which it proposes to suspend/revoke the

license and shall require the EMI to submit to it

within 30 days a written statement of objections

to the suspension or revocation of the license.

Where the SBP is of the opinion that safety,

soundness, reliability or efficiency of an EMI is

or may be threatened, it may, without prior

notice, suspend or revoke the permission of

EMI.

Governance Arrangements

Regulation 9

EMI shall have adequate governance

arrangements to ensure integrity of its e-money

business. EMI shall follow the Code of

Corporate Governance issued by SECP as far

as the provisions thereof do not conflict with any

provisions of the PS&EFT Act and other

relevant regulations issued by SBP.

Fit and Proper Test [“FPT”]

FPT to be applicable to sponsor shareholder(s),

Directors, CEO and Key Executives of the

prospective EMI. The fitness and propriety will

be assessed as per the requirements

mentioned in Annexure D-4.

The Directors and CEO would require prior

clearance from SBP before assuming their

responsibilities. The compliance of FPT for Key

Executives would be the responsibility of EMI

and the relevant record shall be made available

to SBP as and when required.

Any changes in the information pertaining to the

persons subject to FPT should immediately be

submitted to PSD. Any violations, misreporting

and delay in submission of information to SBP

may result in withdrawal of SBP’s

approval/license or penal action or both under

PS&EFT Act.

The appointment, compensation package,

promotion/demotion and renewal of the



employment contracts of Key Executives shall

be duly approved by the Board of Directors of

the EMI.

EMI shall also develop and implement

appropriate screening procedures to ensure

high standards and integrity at the time of hiring

all employees. In case it is found at any stage or

during the course of inspection by SBP that FPT

guidelines have not been followed or the

incumbent is not a fit and proper person, strict

action shall be taken under the relevant

provisions of PS&EFT Act.

Responsibilities of Board of Directors [“BOD”]

The main responsibilities of BOD are as follows:

Define the key roles and responsibilities of the

directors and senior management.

Approve and monitor the objectives, strategies

and the business plans of the EMI and oversee

that the affairs of the institutions are performed

within the framework of applicable laws and

regulations.

Determine, review, approve and ensure

implementation of internal policies, risk

management, internal control systems, audit, IT

security, human resource etc.

Create a separate department for internal audit

duly approved by the BOD.

BOD can remove CEO with a prior notice of 2

months from the date of the notice issued where

the BOD, acting reasonably, are of the opinion

that the CEO has acted fraudulently,

negligently, or in material breach of the EMI’s

policies, procedures or his/her employment

agreement. Acting CEO appointed pursuant to

resignation/removal of the CEO is required to

meet FPT criteria prescribed for CEO and the

EMI shall duly submit FPT documents to SBP

before assumption of the charge.

In case of temporary vacation (not exceeding

one month) of the office of CEO, EMI shall

ensure to entrust charge of the office of CEO to

an officer who meets the FPT Criteria

prescribed for Key Executives and whose FPT

documents have already been submitted to

SBP.

Where office of any Director/CEO falls vacant,

such position can only be filled with prior

approval of SBP. However, any new

appointment / placement of Key Executives

other than Directors or CEO shall be intimated

to SBP within seven days of appointment /

placement.

Management

No member of BOD of an EMI shall be

appointed in the EMI in any capacity except as

CEO of the EMI who holds 10% or more of

paid-up capital either individually or in concert

with family members. In addition, maximum two

members of the BOD of EMI can be the

Executive Directors including its CEO.

The BOD of EMI shall appoint a qualified and

experienced person as Compliance Officer who

shall report directly to the CEO and shall be

responsible for effective compliance of all the

relevant rules, regulations, laws and timely

submission of required accurate data, returns

and other information, as required by SBP from

time to time.

Capital Requirements

Regulation 10

Startup capital requirement of becoming an EMI is

PKR 200 million and the minimum ongoing capital to

be maintained at all times shall be as follows:

Slabs

Average Daily

Outstanding E-

Money Balance

(OEB)

On-Going

Capital Required

1. Up to PKR 4

Billion

PKR 200 million

2. Between PKR 4

Billion and PKR

10 Billion

PKR 200 million plus

5% of (OEB) in excess

of PKR 4 Billion

3. Between PKR

10 Billion and

PKR 20 Billion

PKR 500 Million plus

7.5% of (OEB) in

excess of PKR 10

Billion

4. Above PKR 20

Billion

PKR 1.25 Billion plus 10% of (OEB) in excess of PKR 20

Billion*

* EMI is required to inform SBP as soon as OEB

exceeds PKR 20 million.



The items qualified for calculating initial as well

as ongoing capital are given in Annexure B.

Security Deposit at SBP-BSC shall be

maintained at least ten percent (10%) of the

required capital or any other amount prescribed

by SBP. 5% of the security deposit will be kept

in a non-remunerative current account with the

SBP Banking Service Corporation and five

percent (5%) in the form of Government

securities to be kept under lien at SBP-BSC.

Customer Due Diligence

Regulation 11

Following are the requirements which are required

to be fulfilled by EMI while issuing e-money

payment instruments:

1. Collect at least the following customer

information:

Name

Father/spouse’s name

CNIC

Mobile Number

Residential Address

Any other two field information which is not

present on CNIC such as place of birth,

mother’s name etc.

Customer is required to provide a copy of

CNIC and a live digital photo (where

applicable).

2. Use at least Two-Factor Authentication for

customer verification

3. Activate e-money payment instruments only

after verification of customers’ particulars as

well as after pre-screening for designated and

proscribed persons before initiation of customer

relationships or allowing use of payment

services.

4. Allow their customers one credit/fund transfer

transaction before verification of customers’

credentials. In case, the customer’s credentials

are not verified then e-money payment

instrument/account shall be closed and EMI

shall file an STR accordingly.

5. Conduct additional due diligence of those

customers who are categorized as high risk as

per AML/CFT regulations and risk based

guidelines of SBP.

6. Take consent of customers on the terms and

conditions of e-money payment instruments

including the charges/fee associated with such

instruments. The copy of terms and conditions

shall also be made available to customers

through various channels like email, website,

brochures, mobile phones, IVR etc.

7. Ensure that a CNIC holder can obtain/open

only one e-money payment instrument with an

EMI.

8. Send transaction alerts in real time to their

customers for all transactions.

9. During issuance of e-money payment

instruments or during transaction processing,

identify any suspicious activity and report such

transactions to FMU in the form of STRs.

10. Ensure compliance of domestic and

international sanctions obligations i.e. freezing

of assets and non-provision of services to

individuals/entities designated/proscribed by the

UN Security Council or by the Government of

Pakistan under the Anti-Terrorism Act, 1997.

e-Money payment instruments’ limit

Regulation 12

The aggregate monthly load limit of an e-money

payment instrument shall be Rs. 50,000 and Rs.

200,000 on biometric verification of CNIC from

NADRA.

Cash withdrawal limit for e-money holders shall

be Rs. 10,000 per day subject to biometric

verification or at least two-factor authentication.

Issuance and redemption of e-money payment instruments

Regulation 13

EMI to issue an e-money payment instrument

without any delay at par value on receipt of

funds.

e-Money payment instruments can be funded

through:



I. Interbank Fund Transfer (IBFT) using any

ADCs.

II. Cash in at EMI branches/agent

locations/ATMs/bank branches. The one

through agent’s location shall be subject to

biometric verification.

EMI to redeem e-money payment instruments

at par value at any time upon the request of e-

money holder without any charges. Further,

biometric verification is required, in case of

redemption of e-money in cash.

Safeguarding customers’ funds

Regulation 14

EMI shall not co-mingle its company funds with

the funds received from users/customers. A

separate account is required to be maintained

with a licensed bank (trustee) that at least has

‘A’ rating from a credit rating agency.

EMIs shall not place more than 50% of e-

money balances with one Trustee.

In case the rating of the trustee is downgraded,

then it shall change the trustee within three

months and inform SBP accordingly.

EMI shall submit copy of their trust account

agreement with the SBP.

EMIs are allowed to invest 50% of the last three

months daily average outstanding e-money

balance in government securities with maturity

up to one year.

Use of Agents

Regulation 15

EMI shall solicit prior one time approval in

writing from SBP to engage agents for providing

payment services to EMI’s customers.

EMI can use the existing Branchless Banking

agent network.

EMI shall develop a central policy on the Agent

Network Management [“ANM”] duly approved

by its Board.

EMI shall ensure that agents do not represent

themselves as an EMI or staff of EMI.

The SBP shall have powers to advice and

request EMIs and agents for data and

information, inspection of the books and

premises of the agent, direct an EMI to instruct

its agent, terminate agreement with agent, take

remedial action arising from the conduct of an

agent at any time as SBP may deem necessary.

EMI shall publish an updated list of all agents

and locations on their websites and assign

transaction limits to agents on the basis of

potential business volume.

EMI shall not issue e-money payment

instruments through its agents.

EMI shall sign SLA/Agency Agreement with

agents detailing the functions to be performed

by agent along with roles, responsibilities and

obligations of the EMI and its agents.

Fees / revenue sharing structure, responsibility

for bearing up-front/ running costs of EMI

operations shall also be defined in the

agreement.

The agent shall ensure secrecy of customer

data / information and all transactions in

accordance with all applicable laws and

regulations.

Interoperability

Regulation 16

SBP will mandate interoperability of applicant EMIs

with other EMIs, banks/MFBs, PSOs/PSPs at an

appropriate time. For this, EMIs shall have open

systems to become interoperable with other

payment systems in Pakistan. However, EMIs are

encouraged to enter into this arrangements right

from their inception.

Outsourcing of functions to third parties

Regulation 17

No function can be outsourced outside Pakistan

without prior written approval from SBP.

For outsourcing, EMI shall follow the

instructions specified in Framework for

Outsourcing Risk Management by Financial

Institutions as issued and amended by SBP

from time to time.



Outsourcing shall not release the EMI from its

primary responsibility of security, integrity and

confidentiality of data/information.

Complaint handling mechanism

Regulation 18

EMIs need to ensure that adequate measures

for customer protection, awareness and dispute

resolution are in place as they will deal with a

large number of first time customers with low

financial literacy level.

EMIs shall have appropriate customer

protection against risks of fraud, loss of privacy

and even loss of service.

EMI, shall have board approved dispute

resolution mechanism to settle all disputes.

EMI shall have a proper and separate complaint management mechanism for resolution of the customer complaints.

EMIs shall have customer awareness programs

that should cover use of e-money payment

instruments, protection against frauds and rights

and obligations to use EMIs services etc.

Security and Confidentiality

Regulation 19

For fidelity and secrecy of the information, the EMI

shall:

Ensure that personal information of customers

is used, disclosed, retained and protected as

committed or agreed;

Ensure the Security, Integrity, Confidentiality

and Availability of data and services as per the

international standards and SBP guidelines

prescribed from time to time;

Comply with the relevant Sections of PS&EFT

Act, 2007;

Get their systems audited from SBP’s approved

Panel of Auditors before commencement of

their business operations and thereafter on

annual basis; and

Report all security breaches to relevant

stakeholders including PSD, SBP along with the

detailed report as per annexure “B” to the EMI

regulations.

AML/CFT Requirements

Regulation 20

To mitigate the risk of money laundering and

terrorist financing activities, EMIs shall:

Deploy the automated transaction monitoring

system to proactively monitor the transactions;

Comply with all the AML/CFT Laws, Guidelines,

Regulations issued by SBP or any other

authority from time to time;

Identify and assess the ML/TF risks that may

arise in relation to the development of new

products and new business practices, including

new delivery mechanisms and the use of new or

developing technologies for both new and pre-

existing products; and

Conduct risk assessments prior to the launch or

use of new products, practices and

technologies.

Risk Management Mechanism

Regulation 21

EMI must have:

overall risk management including enterprise

risk management policies and procedures duly

approved by the Board. Where applicable, EMI

shall ensure compliance with SBP’s Enterprise

Technology Governance & Risk Management

Framework for Financial Institutions as issued

vide BPRD Circular No. 05 of 2017 dated May

30, 2017.

approved policies and procedures for

information, systems security and necessary

internal controls in place.

BCP and DRP drills to be conducted half-yearly

in first two years of commencement of

operations and quarterly thereafter and results

of the drills be recorded in a formal report as per

the international best practice.



Oversight of EMIs Regulation 22

Following are the reporting requirements for EMI:

Annual audited financial statements shall be

submitted to SBP within three months of the

financial year-end.

Capital Returns shall be submitted to SBP on

quarterly basis.

EMIs shall calculate the ongoing capital after

three months from the commencement of their

e-money business. For calculating on-going

capital, average daily outstanding e-money over

the preceding three months shall be taken into

account.

EMI shall submit the following information as

per the frequency set by SBP from time to time:

A The number of e-money payment

instruments issued

B The volume and value e-money

transactions

C Incidents of fraud, theft and robbery

including at its agents

D

Material service interruptions and

major security breaches as per

Annexure B.

The SBP may at any time request for any other

information from EMI, any of its agents and its

associated bank.

Record Retention

EMIs shall maintain all necessary records for at

least 10 years or as required by the relevant

laws.

EMIs shall keep all records obtained through

CDD measures, business correspondence, and

results of any analysis undertaken, following the

termination of the business relationship as

required by the relevant laws.

EMIs shall ensure that transaction records

should be sufficient to permit reconstruction of

individual transactions so as to provide, if

necessary, evidence for prosecution of criminal

activity.



Glossary

AML/CFT Anti-Money Laundering and Countering of Financing Terrorism

BOD Board of Directors

EMIs Electronic Money Institutions

FMU Financial Monitoring Unit

FPT Fit and proper test

MFB Microfinance Bank

PS&EFT Act Payment Systems and Electronic Fund Transfers Act, 2007

PSO/PSP Payment Systems Operator/Payment Service Provider

PSD Payment Systems Department

Regulations Electronic Money Institutions [“EMIs”] Regulations

STR Suspicious Transaction Report

SBP State Bank of Pakistan



Definitions

Electronic Money Institution or EMI

Non-banking entities duly authorized to issue payments in the form of electronic money.

Electronic Money or e-money

Monetary value as represented by a claim on the issuer which is stored in an electronic including magnetic device or Payment Instrument, issued on receipt of funds of an amount not less in value than the monetary value issued, accepted as means of payment by undertakings other than the issuer and includes electronic store of monetary value on an electronic device that may be used for making payments or as may be prescribed by the State Bank.

e-Money holder Any person to whom the e-money has been issued or any person who uses the e-money to make payments for purchases of goods and services and who has a claim on e-money issuer for the e-money issued by the EMI.

Aggregate monthly load limit

Total amount of e-money transferred/loaded into an e-money account held by an e-money holder over the period of a calendar month.

Average outstanding e-money

Average amount of balances maintained by an EMI with licensed banks related to e-money in issue, for any given period and in the manner as defined by SBP.

Issuer EMI which issues e-money payment instruments.

Key Executive

Payment Instrument Any instrument issued by EMIs, whether tangible or intangible, that enables a person to obtain money, goods or services or to otherwise make payment; but excludes Payment Instruments prescribed in Negotiable Instrument Act, 1881

Payment Services Services that enable the customers to make payments for goods and services, bill payments, fund transfers, cash deposit and withdrawal from e-money accounts.

Trust Account An account maintained by an EMI with a licensed bank in Pakistan in which the EMI is required to place all funds collected from its customers against the issuance of e-money and is segregated from EMI’s own funds.



Offices in Pakistan

Karachi Office

Sheikh Sultan Trust Building No. 2

Beaumont Road

Karachi 75300

Phone +92 (21) 3568 5847

Fax +92 (21) 3568 5095

eMail [email protected]

Lahore Office

351-Shadman-1, Main Jail Road,

Lahore Pakistan

Phone +92 (42) 111-KPMGTH (576484)

Fax +92 (42) 3742 9907


Islamabad Office

Sixth Floor, State Life Building

Blue Area

Islamabad

Phone +92 (51) 282 3558

Fax +92 (51) 282 2671


www.kpmg.com.pk

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registered in Pakistan and a member firm of the KPMG

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KPMG Taseer Hadi & Co. Chartered Accountants A … brief...5. Multilateral routing, switching and/or processing of payment transactions Any other activity permitted by SBP. 6. Any